Question 1

What is a whistleblower system?

Accepted Answer

If you believe that a violation of a law or regulation has occurred or will occur in your
workplace or elsewhere in the organisation, we encourage you to report your knowledge or
concerns.

You can make the report to your direct superior or the management.
You are also welcome to use our whistleblower system.

You can use the whistleblower system to report any type of breach of the law, such as fraud,
corruption, insider trading, discrimination, (sexual) harassment, serious breaches of IT
security and other serious matters. The report will be received and processed by an external
law firm and full confidentiality is guaranteed. You can choose to remain completely
anonymous. All reports are welcome.

Question 2

Why do you need an internal reporting channel?

Accepted Answer

One reason for setting up a whistleblower system is that it is legally required. Once the Whistleblower Protection Act, which is currently in the final legislative phase, comes into
force, all organisations with more than 249 employees will be obliged to set up an internal reporting channel.

The obligation will only apply to smaller organisations with more than 49 employees but no more than 249 employees from 17.12.2023.

In our view, however, better reasons lie in the establishment of a culture of speaking up and in
the fact that a whistleblower system is or should become an important part of the organisation's compliance management system.

Question 3

What are the aims of a whistleblowing system?

Accepted Answer

The establishment of the LockLine “whistleblower system with ombudsperson”, offered by
us, provides an internal reporting channel and thus fulfils the legal obligations under the
Whistleblower Act.

However, our LockLine whistleblower system with ombudsperson can do much more, and its
objective is more far-reaching.
The aim is to reliably prevent and/or detect violations through reports, as these can lead to
considerable financial disadvantages for your organisation and reputational damage.
Our aim is therefore not just to formally fulfil the legal requirements, but to establish a truly
functioning and effective whistleblowing system.

Question 4

Why should you set up a system enabling anonymous tips?

Accepted Answer

The special appeal of an internal reporting channel also includes the option of submitting anonymous
reports. An anonymous whistleblower feels safer and will disclose misconduct more readily and
easily than one who is obliged to disclose their name. Our LockLine whistleblower system with
ombudsperson enables anonymous reporting. Even if the name is disclosed, the whistleblower is free
to decide whether or not it is passed on to the organisation. The whistleblower's decision to remain
anonymous is safeguarded by the ombudsperson, with their professional duty of confidentiality.
Right from the start, the whistleblower is in a very safe environment, our “LockLine”, something
which makes our ombudsperson-backed whistleblower system particularly attractive and encourages
the whistleblower.

Question 5

What is the advantage of an ombudsman?

Accepted Answer

The attractiveness of an internal whistleblowing channel is decisively determined by the level of
confidentiality applied to the information and what consequences a report will have. If the internal
reporting channel is set up within the organisation itself, there is a regular risk of conflicts of interest.
The whistleblower might not disclose if they have doubts about the confidentiality and seriousness
with which their tip will be treated. The solution of bringing in an external person of trust largely
rules out conflicts of interest. It also ensures compliance with the legally prescribed processes and
the daily functioning of the reporting channel, which would have to be safeguarded by deputisation
rules in the event of the responsible person being on holiday or sick.

Question 6

What does your communication package mean?

Accepted Answer

The whistleblowing hotline will work effectively and achieve its objectives if the installation,
working methods and compliance with confidentiality are well communicated within the
organisation. We will provide you with our communication package for this purpose.
It is also important to communicate potential follow-up measures.

An annual evaluation must be carried out to check whether the whistleblowing hotline is
working and/or whether it needs to be improved and adapted.

Question 7

What kind of reports can you submit?

Accepted Answer

In principle, you can always submit a report if you have the feeling that something is not
going according to the rules. The whistleblower hotline can therefore be used, for example, to report:

• Violations of guidelines
• Human rights risks or violations
• Environmental risks or injuries
• Conflicts of interest
• Corruption
• Fraud
• Theft
• Insider trading
• Inappropriate gifts and hospitality
• Breaches of confidentiality
• Bribery and payoffs
• Inappropriate customer billing
• Inappropriate reporting of expenses
• Violations against data protection
• Harassment
• Discrimination
• Falsification of official documents
• Disregard for occupational health and safety and work-related health hazards

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